NAICS 238160 · Construction
OSHA Recordkeeping for Roofing Contractors
Roofing crews work out of a shop or yard and move from job to job. For recordkeeping, the establishment is the office or yard that sends them out (29 CFR 1904.46), and a roof job that won't last a year doesn't need a log of its own: one 300 log can cover all of those short-term jobs (1904.30(b)(1)). Crews also grow in summer, which is what usually decides the size exemption.
Who keeps and files OSHA records
NAICS 238160 is not on OSHA's partially exempt list, so the size rule decides the log (29 CFR 1904.1 (opens in a new tab)) and the filing appendices decide what goes to OSHA (1904.41 (opens in a new tab)).
- OSHA 300, 300A and 301
- Required
- Once the company passes 10 employees at any time in the year.
- 300A e-filing by March 2
- From 20 employees
- Per establishment; appendix A industry.
- 300 and 301 case data
- From 100 employees
- Per establishment; appendix B industry.
2024 injury rates for roofing contractors
Cases per 100 full-time workers, as published by BLS for NAICS 23816, roofing contractors. The TRIR of 2.4 is above the private-industry rate of 2.3.
- Total recordable (TRIR)
- 2.4
- Columns H, I and J
- Days away, restricted or transferred (DART)
- 1.7
- Columns H and I
- Days away from work
- 1.1
- Column H
| Full-time employees | Hours worked a year | Cases at TRIR 2.4 |
|---|---|---|
| 25 | 50,000 | 0.6 |
| 50 | 100,000 | 1.2 |
| 100 | 200,000 | 2.4 |
Your rate is recordable cases × 200,000 ÷ hours worked; the TRIR calculator works it out from your 300A.
Recordable or not: cases from roofing contractors
- Stitches or staples for a cut from flashing are medical treatment, so the case is recordable. Butterfly bandages or Steri-Strips are first aid. (29 CFR 1904.7(b)(5)(ii))
- A fall that puts a worker in the hospital as an in-patient has to be reported to OSHA within 24 hours, on top of going on the log. (29 CFR 1904.39(a)(2))
For a case of your own, the recordable checker walks through the same rules.
What 29 CFR 1904 requires
OSHA 300 log
Each recordable case, within 7 calendar days. 1904.29(b)(3) (opens in a new tab)
OSHA 301 report
One per case, same 7 days; an equivalent form works. 1904.29(b)(4) (opens in a new tab)
OSHA 300A summary
Certified by an executive, posted February 1 to April 30. 1904.32 (opens in a new tab)
Privacy cases
Six case types keep the name off the log. 1904.29(b)(7) (opens in a new tab)
Severe injury reports
Fatality in 8 hours; hospitalization, amputation, eye loss in 24. 1904.39 (opens in a new tab)
Retention
All three forms kept five years. 1904.33 (opens in a new tab)
Hazards OSHA addresses for this work
Roofing Contractors: recordkeeping questions
Does a roofing contractor with 12 employees have to keep an OSHA 300 log?
Yes. Roofing isn't on OSHA's partially exempt list, so the only exemption is size: a company with 10 or fewer employees at all times during the last calendar year doesn't keep the log (29 CFR 1904.1). The test uses the whole company's peak headcount, so a summer crew that takes you from 8 to 12 people for a month puts you over for that year.
Does a roofing contractor have to file injury data with OSHA by March 2?
An establishment that had 20 or more employees at any time last year submits its 300A through OSHA's Injury Tracking Application by March 2, because construction is in appendix A to 29 CFR 1904.41. Roofing is also in appendix B, as part of NAICS 2381, so an establishment with 100 or more employees submits its 300 log and 301 case data as well, without employee names or addresses. The counts are per establishment, not for the whole company.
What is the difference between the OSHA 300 and the 300A for a roofer?
The 300 is the running log: each recordable case on its own line within 7 calendar days (29 CFR 1904.29(b)(3)). The 300A is the year-end summary of that log, certified by a company executive and posted from February 1 to April 30 (1904.32). At the 2024 roofing average of 2.4 recordable cases per 100 full-time workers, a 40-person company would log about one case a year, and a year with none still gets a 300A, with zeros.